Smartsupp and the EU AI Act: does your chat widget tell people it's AI?
Smartsupp's Mira is an AI shopping assistant built for ecommerce, and its setup is explicit about humanizing the bot: you type a name, choose a gender, and pick an avatar from a gallery, and that identity displays in the widget header and next to every message Mira sends. That's an unusually direct version of the Article 50(1) tension — the product's own onboarding flow asks you to give an AI a human name and a gendered face before it ever talks to a visitor.
The rule itself is short. Article 50(1) of the EU AI Act requires AI systems that interact directly with people to be designed so users know they're dealing with AI — no later than the first interaction, in a clear and distinguishable way. The exception for cases where it's "obvious" is narrow: a natural-language customer-service bot doesn't qualify just because it has a robot icon. A line in your terms of service doesn't satisfy it either. And it's easy to enforce, because a regulator can simply open your site and start a chat.
Where the disclosure lives in Smartsupp
In a typical Smartsupp setup, the surfaces that can carry (or fail to carry) the AI disclosure are:
- The chat widget header, which displays Mira's configured name and avatar throughout the conversation
- The welcome message, which can be set to greet visitors immediately or only after they message first
- Mira's generated replies — product recommendations and answers drawn from your site and product feed
- The handover point when Mira transfers to a human operator, typically on request or when she lacks enough information
Your Smartsupp disclosure checklist
- Open your storefront in a private window and start a chat: does anything say "AI" before or in Mira's first reply, given her name and avatar are front and center in the header?
- Revisit the name/gender/avatar you chose during setup — a human first name with a photorealistic avatar is the exact combination that needs an explicit AI line to balance it
- Add the AI statement to the welcome message so it's visible before a visitor even sends their first message
- Check both welcome-message-first and message-triggered activation modes, since the disclosure needs to survive either configuration
- Confirm the handover-to-human moment is announced in the conversation, not just reflected in faster or different-sounding replies
- Screenshot the widget header and first-interaction state, and export Mira's name/avatar/welcome-message configuration with a date
Watch out for
Smartsupp built Mira's setup around making the assistant feel like a real team member — a named, gendered, illustrated character greeting shoppers in the widget header. That's effective ecommerce UX and a near-textbook case of what Article 50(1)'s "obvious from context" exception was not written to cover: a human-presenting figure that never says, anywhere, that it's AI.
Common questions
Mira comes with a friendly designed avatar by default — doesn't that style already read as "obviously a bot"?
Not reliably. Illustrated or cartoon-style avatars still read as a character with a name and gender, not necessarily as "this is AI" — the safer assumption is that avatar style alone doesn't do the disclosure work, so keep an explicit line in the greeting.
Mira hands off to us when she's unsure — do we need to relabel anything at that point?
Yes, briefly — let the visitor know a human has joined. It doesn't need to be dramatic, just clear enough that they know who they're talking to now versus a moment ago.
Check it in one scan.
DisclosureProof opens your site the way a regulator would, triggers your Smartsupp widget, and records whether the AI disclosure actually appears — with timestamped evidence either way.
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